In light of Notification No. 12/2024 - Central Tax dated 10th July 2024, read with Notification No. 20/2024 - Central Tax dated 8th October 2024, changes in reporting for Form GSTR-9 have been introduced for FY 2023-24 onwards. The total input tax credit (ITC) available for inward supplies is now auto-populated in Table 8A of GSTR-9 based on GSTR-2B for the respective financial year.

Meanwhile, Table 8C of GSTR-9 requires manual entry of ITC on inward supplies received during the FY but availed in the next FY within the permissible period. This change has raised several queries regarding mismatches between the values in Table 8A and Table 8C, particularly due to differences in data sources (GSTR-2A for FY 2022-23 and GSTR-2B for FY 2023-24). Below are common issues and recommended solutions to ensure compliance and accurate reporting:

Common Scenarios and Reporting Guidelines

1. Invoice Dated FY 2023-24, Reported Late in GSTR-1

Issue: The supplier files GSTR-1 post-March 2024, making the invoice part of the next year’s GSTR-2B.
Solution:

• Report this ITC in Table 8C and Table 13 of GSTR-9 for FY 2023-24, as it pertains to the current FY.
• Align reporting with the instructions for Table 8C and Table 13 of Form GSTR-9.

2. ITC Claimed and Reversed in FY 2023-24, Reclaimed in FY 2024-25

Issue: ITC is reversed due to non-payment to the supplier within 180 days (as per Section 16(2)) but reclaimed after payment in FY 2024-25.
Solution:

• Report the reclaimed ITC in Table 6H of GSTR-9 for FY 2024-25.
• Do not include this in Table 8C or Table 13 of GSTR-9 for FY 2023-24.
• This approach applies to reclaims under Rule 37A as well.

3. ITC Claimed, Reversed, and Reclaimed Due to Goods Received Late

Issue: ITC claimed in FY 2023-24 and reversed due to non-receipt of goods (as per Circular 170), then reclaimed in FY 2024-25.
Solution:

• Report reclaimed ITC in Table 8C and Table 13 of GSTR-9 for FY 2023-24.

4. FY 2022-23 Invoice in Table 8A of FY 2023-24

Issue: Supplier files GSTR-1 late, causing FY 2022-23 invoices to appear in Table 8A of FY 2023-24.
Solution:

• Exclude these values from Table 8C and Table 13 of GSTR-9 for FY 2023-24.
• Report only current FY data in Tables 4, 5, 6, and 7, per Instruction 2A of the notified form.

5. ITC Claimed, Reversed, and Reclaimed in the Same FY

Issue: Invoice ITC is claimed, reversed, and reclaimed within FY 2023-24.
Solution:

• Declare this ITC in Table 6H of GSTR-9.
• Do not duplicate reporting under Table 7 or elsewhere, as clarified by the CBIC press release dated 3rd July 2019.

Key Takeaways

• Understand the source differences (GSTR-2A vs. GSTR-2B) and how they impact auto-population.
• Ensure that only current FY transactions are reported in relevant tables.
• Reclaimed ITC should be correctly reported based on timing and instructions for specific tables.

By adhering to these guidelines, taxpayers can minimize mismatches and ensure accurate compliance with the revised norms for FY 2023-24 annual returns.

The concept of e-Invoicing under the Goods and Services Tax (GST) regime is transforming the way businesses report their invoices. Contrary to popular belief, e-Invoicing does not imply generating invoices on a government portal but involves reporting specific GST document details to an Invoice Registration Portal (IRP) and obtaining a unique Invoice Reference Number (IRN). Let’s dive into the key components of this system and its operational framework.

1. What is e-Invoicing?

e-Invoicing is the process of digitally reporting invoice details to government-notified portals. Businesses upload these invoices to the IRP, where they are validated and assigned a unique IRN.

2. Key Components of e-Invoicing

Invoice Registration Portal (IRP):
IRPs are government-approved platforms for reporting invoices. Currently, six IRPs are authorized to generate IRNs free of charge under Rule 48(4) of the CGST Rules.

Invoice Reference Number (IRN):
IRN is a unique identifier generated for each invoice by hashing the supplier's GSTIN, financial year, document type, and document number.

Annual Aggregate Turnover (AATO):
AATO is calculated based on the taxpayer's PAN and GSTR-3B returns. It determines the applicability of e-Invoicing requirements for businesses.

Enablement for e-Invoicing:
Taxpayers are automatically enabled for e-Invoicing based on their AATO. If not enabled, they can self-register on the e-Invoice portal (https://einvoice.gst.gov.in).

e-Invoice QR Code:
A QR code with essential invoice details, such as GSTINs, invoice number, date, value, and IRN, is generated for each e-Invoice.

3. Key Features of e-Invoicing System

Auto-Population in GSTR-1:
Once validated, e-Invoice details are automatically populated in the supplier's GSTR-1 return form, streamlining compliance.

Standardized Schema:
The e-Invoice schema (INV-1 Version 1.1) defines mandatory and optional fields for consistent data representation.

Master Codes:
Predefined codes like HSN, state, country, and currency codes standardize the e-Invoicing process.

API for Reporting:
IRPs provide API-based integration for seamless reporting of invoice details from existing ERP systems.

Signed e-Invoices:
After validation, the IRP digitally signs e-Invoices, assigning them a unique IRN and QR code.

4. How e-Invoicing Impacts Business Operations

ERP Integration:
Businesses can continue generating invoices through their ERP systems. However, B2B invoice details must be reported to the IRP in a predefined JSON format.

Simplified Compliance for B2B Transactions:
Currently applicable to certain taxpayers based on their turnover, e-Invoicing enhances transparency and reduces errors in B2B transactions.

Verification via GSTN e-Services App:
The app allows users to verify e-Invoices by scanning QR codes, check IRN status, and access return filing details.

5. Benefits of e-Invoicing

• Enhanced Compliance: Real-time validation of invoices ensures accurate reporting and minimizes discrepancies.
• Cost Efficiency: Free IRN generation on IRPs reduces compliance costs.
• Data Security: Digitally signed invoices improve data integrity and prevent fraudulent practices.
• Seamless Integration: Auto-population and API-based integration simplify GST filing and reduce manual intervention.

6. Navigating e-Invoice Portals

The official e-Invoice Front Office Portal (https://einvoice.gst.gov.in) provides functionalities like enablement status checks, IRN searches, schema guidelines, and links to IRPs.

Conclusion

e-Invoicing is a significant step toward digitizing tax compliance under GST. It not only streamlines the reporting process but also ensures accuracy and transparency in B2B transactions. Businesses should adopt this system to enhance their compliance and operational efficiency.

Understanding e-Invoicing in GST: A Comprehensive Guide

In an effort to enhance transparency and improve the ease of doing business, the Government of India introduced the concept of e-Invoicing under GST. This initiative streamlines the process of invoice generation, reporting, and validation. Let’s dive into the details of e-Invoicing, its applicability, and the processes involved.

What is e-Invoicing?

e-Invoicing refers to the reporting of specific GST documents to a Government-notified portal called the Invoice Registration Portal (IRP) to obtain a unique Invoice Reference Number (IRN).

It’s important to note that e-Invoicing does not mean generating invoices directly on a government portal. Businesses will continue to create invoices using their own Accounting, Billing, or ERP Systems. The invoices are then uploaded to one of the six authorized IRPs in a standardized format, called Form GST INV-1 (Schema), at no charge.

Who Needs to Comply with e-Invoicing?

e-Invoicing is applicable to taxpayers whose aggregate turnover exceeds the notified threshold in any preceding financial year since 2017-18.

• As of August 1, 2023, businesses with an Annual Aggregate Turnover (AATO) of ₹5 crores or above are required to comply with e-Invoicing regulations.

Exemptions from e-Invoicing

Certain entities and taxpayers are exempt from the e-Invoicing requirements. These exemptions are notified by the Government from time to time. Businesses are advised to refer to the official notifications for detailed exemption criteria.

Documents Covered Under e-Invoicing

The following documents are subject to e-Invoicing requirements:

• GST Invoices
• Credit Notes and Debit Notes related to B2B supplies
• Supplies to SEZs (Special Economic Zones), both with and without payment
• Exports, both with and without payment
• Deemed Exports

How Does the e-Invoicing Process Work?

1. Invoice Creation:
   Businesses generate invoices using their existing Accounting/Billing/ERP systems.
2. Reporting to IRP:
   These invoices are reported to any of the six authorized IRPs.
3. Validation and IRN Generation:
   The IRP validates the invoice, assigns a unique Invoice Reference Number (IRN), and returns a signed e-Invoice with a QR code.
4. Issuance to Receiver:
   The e-Invoice, along with the QR code, is issued to the buyer.
   (Note: A GST invoice for B2B transactions is valid only with a proper IRN.)

Steps for Reporting e-Invoices

Step 1: Enablement for e-Invoicing

• Eligible taxpayers are automatically enabled for e-Invoicing.
• Enablement status can be checked at https://einvoice.gst.gov.in.
• If not enabled, taxpayers can self-enable on the same portal.

Step 2: Registration on IRP

• Taxpayers must register on any of the six authorized IRPs to start reporting e-Invoices.
• Registration involves OTP-based verification of the taxpayer's mobile number and email.

Step 3: Reporting e-Invoices

• Invoices are uploaded to the IRP in JSON format using the predefined schema.
• Reporting can be done through multiple methods like offline tools, web tools, mobile apps, or APIs.

Step 4: Auto-Population

• Once validated, e-Invoice data is auto-populated into the supplier's GSTR-1 return in the GST system.

Verification of e-Invoices

Taxpayers can verify e-Invoices using the following methods:

• GSTN e-Invoice QR Code Verifier App: Available on Google Play and App Store.
• Search IRN Functionality: Accessible at https://einvoice.gst.gov.in/einvoice/search-irn.

Comprehensive Resources: e-Invoice FO Portal

The e-Invoice Front Office Portal (https://einvoice.gst.gov.in) serves as a one-stop resource for all e-Invoicing-related functionalities:

• Checking enablement status
• Accessing e-Invoice schema and master codes
• Searching IRNs
• Links to all six IRPs

The portal is expected to offer additional functionalities, such as downloading e-Invoices, in the near future.

Conclusion

e-Invoicing is a game-changer for GST compliance, ensuring seamless integration of invoice reporting with the GST system. It reduces manual intervention, enhances accuracy, and streamlines the filing process for businesses.

To stay compliant and leverage the benefits of e-Invoicing, businesses must ensure timely enablement and proper reporting of invoices. For more details, refer to the official e-Invoice portal.

Source: PIB Delhi

1. Introduction to PAN 2.0 Project

• Objective:
  • Streamline and modernize the issuance and management of PAN and TAN to enhance user-friendliness and efficiency.
• Approval:
  • Received Cabinet Committee on Economic Affairs (CCEA) approval on November 25, 2024.
• Integration of Services:
  • Consolidates all PAN/TAN services currently spread across multiple platforms (e-Filing Portal, UTIITSL Portal, Protean e-Gov Portal) into a single, unified portal.
• Focus:
  • Eco-friendly, paperless processes.
  • Establishing PAN as a common identifier for digital systems in specified Government agencies.

2. Key Features of PAN 2.0

• Unified Portal:
  • A single platform for all PAN/TAN-related services, including:
    • Application and re-issuance.
    • Updates and corrections.
    • Aadhaar-PAN linking.
    • Online PAN validation.
• Paperless Processes:
  • Fully online application and service model to reduce paperwork.
• Cost-Free Services:
  • PAN issuance and updates at no cost (e-PAN delivered via email).
  • Physical PAN card available for a nominal fee.
• Enhanced Security:
  • Introduction of PAN Data Vault to protect sensitive information.
• Support System:
  • Dedicated call centers and helpdesks to resolve user queries.

3. Benefits for Taxpayers

• Faster service delivery and grievance redressal.
• Simplified application and correction processes.
• Robust protection of personal and demographic data.
• Seamless integration with Digital India initiatives.

4. Aligning with Digital India Goals

• PAN 2.0 emphasizes:
  • Paperless, eco-friendly procedures.
  • Strengthening PAN’s role as a common business identifier for Government systems.

5. Frequently Asked Questions (FAQs)

Q1: What is PAN 2.0?

• PAN 2.0 is an e-Governance initiative by the Income Tax Department (ITD) to consolidate and re-engineer taxpayer registration services for both PAN and TAN.
• Key services include online PAN validation, Aadhaar-PAN linking, and centralized updates/corrections.

Q2: How is PAN 2.0 different?

• All PAN-related services will move to a single portal.
• Fully paperless and eco-friendly processes.
• Cost-free allotment and updates.

Q3: Do existing PAN holders need to reapply?

• No, existing PAN holders do not need to reapply. Corrections and updates can be made without reissuance.

Q4: What about duplicate PANs?

• Enhanced system logic will identify and address duplicate PANs.

Q5: What if my PAN lacks a QR code?

• PAN cards issued after 2017-18 already have QR codes. Older PAN holders can request a reprinted card with a dynamic QR code.

6. Conclusion

The PAN 2.0 Project is a transformational step by the Income Tax Department, aimed at providing a seamless, user-friendly, and secure experience for taxpayers. It aligns with the Government's Digital India mission, fostering efficiency, transparency, and sustainability in taxpayer services.

1. Notification Applicability

• Reference: Notification No. 25/2024-Central Tax.
• Effective Date: October 10, 2024.
• Requirement:
  • Any registered person receiving metal scrap supplies (Chapters 72 to 81 of the Customs Tariff Act, 1975) from another registered person must deduct TDS under Section 51 of the CGST Act, 2017.

2. Issue with October 2024 TDS Reporting

• Problem Identified:
  • Taxpayers faced challenges reporting TDS deducted in October 2024 due to delayed GST registration approvals in November 2024.
  • The GSTN system does not allow filing returns for periods prior to the registration approval month.

3. Resolution Mechanism

• Guidance for Affected Taxpayers:
  • Taxpayers registered in November 2024 but who deducted TDS during October 2024 (10.10.2024 to 31.10.2024) should report the consolidated TDS amount for the period 10.10.2024 to 30.11.2024 in the GSTR-7 return for November 2024.
• Purpose:
  • To comply with TDS reporting requirements despite GSTN system limitations.
  • To simplify the filing process for affected taxpayers.

4. Key Takeaways

• Ensure compliance with TDS obligations under Section 51 of the CGST Act.
• Utilize the November 2024 return to account for October 2024 TDS deductions.
• Follow the advisory to avoid penalties or discrepancies in TDS reporting.

Introduction

Managing taxes and GST compliance is vital for every business in India. At MS Chambyal & Associates, we specialize in simplifying complex tax processes for businesses of all sizes. This article breaks down GST and taxation concepts into easy-to-understand terms, ensuring compliance and optimizing financial efficiency.

What is GST?

GST, or Goods and Services Tax, is a unified tax system replacing multiple indirect taxes. It streamlines taxation and promotes transparency.

Types of GST:

• CGST (Central GST): Collected by the central government on intra-state transactions.
• SGST (State GST): Levied by the state government for intra-state supplies.
• IGST (Integrated GST): Applied on inter-state and international transactions.

Benefits of GST Compliance

• Reduced Tax Complexity: A unified system eliminates the cascading tax effect.
• Input Tax Credit (ITC): Businesses can claim credit for taxes paid on purchases.
• Enhanced Credibility: Compliance boosts trust among stakeholders and customers.

GST Filing Deadlines You Must Know

• GSTR-1: File details of outward supplies by the 11th of every month.
• GSTR-3B: Submit a summary return by the 20th of each month.
• GSTR-9: File the annual return by December 31st of the next financial year.

Common Challenges in Taxation

1. Frequent Regulatory Changes
2. Mismatch in ITC Claims
3. Late Filing Penalties
4. Inadequate Record Management

Simplifying Direct Taxes

In addition to GST, businesses must manage direct taxes like income tax and TDS (Tax Deducted at Source). Strategic tax planning can help reduce liabilities while ensuring compliance.

How MS Chambyal & Associates Can Help

Our expert team offers tailored solutions to ensure smooth tax and GST compliance:

• GST Registration & Filing
• Tax Planning & Advisory
• Audit & Record Management
• Efficient TDS Filing

Tips for Hassle-Free Tax Compliance

1. Automate Accounting: Use software like Tally for accurate bookkeeping.
2. Set Reminders: Avoid late fees by staying ahead of deadlines.
3. Hire Experts: Professional consultants provide strategic insights and error-free compliance.

Why Partner with MS Chambyal & Associates?

We are committed to offering professional, transparent, and client-focused services. Whether you're a small startup or an established enterprise, we simplify financial complexities so you can focus on growing your business.

Contact Us Today!

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Ensure the turnover reported matches with GSTR-1, GSTR-3B, and audited financial statements. Mismatch can lead to scrutiny or notices.
Reversals of ITC Not Reported:
Report all ITC reversals under Table 7 correctly, including those related to Rule 42 (input services) and Rule 43 (capital goods).
ITC Mismatches with GSTR-2A:
Reconcile ITC claimed in GSTR-3B with GSTR-2A. Overclaiming ITC can result in liability and interest under Section 50 of the CGST Act.

Incorrect Tax Paid Details:

Ensure the tax paid details in GSTR-9 match with GSTR-3B and the cash/credit ledger. Misreporting here can lead to discrepancies.
Not Reporting Amendments or Adjustments:

Report all amendments made in GSTR-1 and GSTR-3B during the relevant year under Table 10 and Table 11.

Skipping the Late Fee Disclosure:

Disclose late fees, penalties, or interest paid during the year under Table 9 of GSTR-9.
Wrong ITC Claimed under Table 8:

Ensure correct bifurcation of ITC availed in GSTR-3B and matched/unmatched ITC under Table 8A to 8D.
Errors in Reporting Exempt, Nil-rated, or Non-GST Supplies:

Accurately classify exempt, nil-rated, and non-GST outward supplies in Table 5. Misclassification may trigger audits.
Omitting HSN Summary:

Fill the HSN summary in Table 17 for outward supplies and Table 18 for inward supplies, as applicable. Late Filing of GSTR-9:

Filing beyond the deadline attracts late fees of ₹200/day (₹100 CGST + ₹100 SGST) subject to a maximum cap of 0.25% of turnover.
Mistakes to Avoid in GSTR-9C


Non-Reconciliation of Turnover:

Ensure turnover reconciliation between audited financials, GSTR-9, and GSTR-3B under Part II of GSTR-9C.
Ignoring Unreconciled ITC:

Provide explanations for ITC mismatches in Part V of GSTR-9C. Unaddressed discrepancies can lead to scrutiny.
Incorrect Reporting of Tax Payable and Paid:

Verify that tax payable and paid amounts in GSTR-9C match with GSTR-9 and GSTR-3B records. Skipping Adjustments and Amendments:

Record all amendments made during the financial year, especially those in Tables 10 and 11 of GSTR-9. Misclassification of Expenses for ITC:

Ensure expenses are categorized correctly under eligible and ineligible ITC in the reconciliation statement.
Errors in Auditor's Recommendations:

Any additional liability identified by the auditor must be reported accurately. Avoid underreporting or ignoring it.
Incorrect Use of Negative Values:

Avoid using negative values for reconciliations unless explicitly

The Goods and Services Tax (GST) framework in India prioritizes transparency, compliance, and accountability. Recently, an increase in Form GST ASMT-10 notices has been observed for discrepancies in Input Tax Credit (ITC) claims during FY 2020-21. Taxpayers are being asked to reconcile mismatches identified across returns such as GSTR-2A, GSTR-3B, GSTR-9, and GSTR-9C, often within stringent timelines.

Understanding Form GST ASMT-10
Form GST ASMT-10 is issued under Section 61 of the CGST Act, 2017, when discrepancies are detected during the scrutiny of returns. This notice provides taxpayers an opportunity to explain, clarify, or reconcile these variances, failing which further proceedings under Sections 73 or 74 of the Act may follow.
Common Causes of ITC Mismatches

For FY 2020-21, the GST department has primarily identified these mismatches:

Mismatch between GSTR-2A and GSTR-3B: GSTR-2A reflects ITC reported by suppliers, while GSTR-3B is based on the ITC claimed by the recipient. Any discrepancy often triggers scrutiny under Rule 36(4) of the CGST Rules, which restricts ITC claims to the extent matched with GSTR-2A.

Discrepancies in GSTR-9 and GSTR-9C: Annual returns and audit reports must align with the data reported in monthly/quarterly returns. Disparities raise red flags.

Overclaimed ITC or unreported liabilities: Instances where taxpayers inadvertently or otherwise claim ITC beyond the supplier’s output tax liability or fail to report outward tax liabilities. Statutory Timelines under Section 73 The GST Act specifies time limits for issuing show-cause notices (SCN) and passing orders in non-fraudulent cases under Section 73 of the CGST Act:

Issuance of SCN:
Within 2 years and 9 months from the due date for filing the annual return for the relevant financial year. Passing of Orders: Within 3 years from the same due date.

For FY 2020-21:
Annual Return Due Date: 28th February 2022 SCN Issuance Deadline: 28th November 2024 Order Issuance Deadline: 28th February 2025 Responding to Form GST ASMT-10 Receiving Form GST ASMT-10 requires prompt action. Here’s a structured approach to manage this effectively:

Reconcile ITC Claims: Compare ITC in GSTR-2A with that in GSTR-3B to identify and resolve discrepancies early.

Review Annual Returns: Ensure alignment between GSTR-9, GSTR-9C, and monthly/quarterly returns to avoid inconsistencies.

Prepare Documentation: Maintain proper invoices, reconciliation statements, and ITC records to substantiate claims.

Adhere to Timelines: Respond within the prescribed period mentioned in ASMT-10 to avoid escalations under Section 73 or Section 74.

Seek Professional Assistance: Engage GST experts or chartered accountants for detailed reconciliation and addressing complex queries. Proactive Measures to Mitigate Risk

With the SCN issuance deadline fast approaching, taxpayers should:
Regularly conduct ITC reconciliations to stay compliant. Use technology or professional services for error-free return filing and reconciliation. Remain vigilant about notices and adhere strictly to GST provisions. Conclusion Form GST ASMT-10 notices highlight the increasing emphasis on compliance under the GST regime. Taxpayers must ensure meticulous record-keeping, robust reconciliations, and timely responses to address discrepancies effectively. Taking proactive steps and consulting professionals can safeguard against liabilities and penalties while ensuring seamless compliance with GST law.

For assistance with GST compliance and notice responses, please feel free to contact